Memorandum by East of England Regional
Assembly and East of England Local Government Conference (SHC
30)
LONDON-STANSTED-CAMBRIDGE
POTENTIAL GROWTH
AREA
This evidence is submitted on behalf of the
East of England Regional Assembly (EERA) and East of England Local
Government Conference (EELGCthe present Regional Planning
Body [RPB]). It relates solely to the London-Stansted-Cambridge
potential growth area.
BACKGROUND
1. The area focused broadly upon Stansted
Airport was identified as a potential growth area in Regional
Planning Guidance for the South-East (RPG9, published March 2001)
which stated that:
"An interregional study should be undertaken
to investigate what the nature, possible extent and location of
future growth might be within the London-Stansted-Cambridge area."
2. EELGC/EERA co-operated with local authority
and stakeholder partners in preparing such a study, and the final
report "London-Stansted-Cambridge Sub Regional Study: Spatial
Patterns Explored" was completed in July 2002.
3. EELGC is preparing Regional Planning
Guidance (RPG14) for the new East of England region and is currently
consulting the public and stakeholders on RPG Options, including
the London-Stansted-Cambridge study. EELGC recognises that the
area is of significant economic importance regionally and nationally
and that growth would provide an opportunity for the long-term
restructuring of the region and provision of improved east-west
links. However, EELGC has not made any formal response to the
study, and cannot until consultation is completed (16 December
2002) and public comments analysed. This initial submission therefore
addresses the Select Committee's questions mostly in general terms.
Question: The overall scale of housebuilding required
4. The Deputy Prime Minister's statement
did not apportion the increase in housebuilding between the four
potential growth areas. Neither did it distinguish between existing
housing allocations and potential future allocations.
5. The London-Stansted-Cambridge study does
not offer a preferred solution. Instead it offers:
i. four possible spatial patterns for growth,
which can be characterised as:
continuing existing settlement patterns;
focusing on regeneration areas (Harlow
and Lee Valley);
focusing on strongest economies (Cambridge
and Stansted); and
ii. three possible levels of growth, which
can be characterised as:
continuing present growth rates;
regional growth, based on rates slightly
higher than present; and
maximising economic growth, ie regionally/nationally
significant high growth rate.
6. EELGC/EERA accepts the importance of
increasing the supply of housing, particularly affordable housing,
in the short to medium term. This needs urgent action by all those
bodies involved with delivery on the ground. The local authorities
would be happy to explore mechanisms to speed up the implementation
of existing plans, for example as is already happening in the
Cambridge sub-region.
7. However, proposals for major growth in
the London-Stansted-Cambridge corridor pose significant spatial
planning challenges:
(i) the levels of growth set out in the London-Stansted-Cambridge
study's higher growth scenarios are significantly higher than
historic growth ratesmore than three times as high as has
recently been achieved. Table 1 demonstrates this:
Table 1: London-Stansted-Cambridge
study scenarios for East of England region[22]
|
| Growth scenario | Total growth 2001 to
2026 (EoE only)
| Dwellings per
annum (25 yrs)
| % increase, high growth
vs. current rates
|
|
| Present rates | 110,000
| 4,400 | -
|
| High growth | 310,000
| 12,400 | 180%
|
|
(ii) Accommodating major growth poses locational challenges,
because the key economic drivers for growth in the corridor are
Cambridge, Stansted Airport, and central London/Docklands.
(iii) The Cambridge Sub-Region is already subject to significant
long-term growth proposals flowing from RPG6 (East Anglia, approved
November 2000) and now being taken forward in the Cambridgeshire
Structure Plan review. It is unlikely that the Cambridge area
could accept further major growth without harm to the economic
and environmental features that make it attractive;
(iv) The Stansted area has limited capacity for urbanisation.
It has a dispersed pattern of small towns and villages, surrounded
by high quality countryside and agricultural land. These settlements
have already expanded significantly to serve both local needs
and Stansted Airport expansion. Their ability to grow further
without significantly harming either their attractiveness to economic
development, sustainability, or the surrounding countryside/rural
economy, is extremely limited. Development of new settlements
in the area would relieve pressure on existing settlements, but
would only be feasible at higher levels of growth, and would have
significant countryside, rural and possibly Green Belt impacts,
and could raise significant sustainability issues. It would also
affect existing settlements in the immediate vicinity of any potential
site, which is already generating concern and controversy in the
region.
(v) The area has inadequate transport infrastructure.
Road and rail routes are predominantly north-south (M11 and WAGN
line) with very poor east-west links. The north-south routes are
used to capacity for London commuting during the daily peak periods.
Infrastructure to support Stansted Airport expansion has consistently
lagged many years behind need. The M11 has hitherto been designated
by Government (and local government) as primarily a movement corridor,
and development has been resisted to protect this role.
(vi) Regeneration of Harlow, the Lee Valley and north-east
London down to Stratford and the Thames is critical to all growth
options for the corridor. In principle, regeneration and major
growth in these areas could be related to the economic growth
potential of Stansted Airport, and the Lee Valley Regional Park
could provide a framework for high quality sustainable development.
However, major growth at Harlow and in the Lee Valley could have
Green Belt impacts. They are also distant from Stansted. Harlow
is about 12 miles south, and the Lee Valley 25-30 miles. It would
only be acceptable to create new commuter flows on this basis
if extremely high quality, affordable public transport could be
provided. It is arguable that restraint on private car-based transport
would be needed to make this work. Even with successful public
transport provision, any large scale affordable housing provisionie
housing occupied by key workers and people on low incomeswould
be distant from a key source of employment.
(vii) London provides the other economic growth driver
for the corridor, but could only sustain significant housing development
in the East of England region if a significant increase in commuting
could be accepted. The figures shown in Table 1 above exclude
potential housing growth within the GLA area. The London-Stansted-Cambridge
study also suggested the potential for providing between 117,000
and 200,000 dwellings in London, additional to the figures in
Table 1. While significant public transport investment is planned
or proposed that could serve this growth (mainly the Crossrail
2 proposal), EELGC has objected to the Mayor of London's "London
Plan" on the basis that the schemes are being proposed as
London-focused Metro systems that would not adequately support
areas outside London.
Question: Are the proposals likely to significantly reduce
house prices
8. The London-Stansted-Cambridge study noted that:
"There is some debate about how much effect on prices
increasing the supply of residential land would haveespecially
in the short term and in the context of constrained supply throughout
the South of England. However, there is no doubt that the relative
level of supply also has a major influence on land and property
prices in the long runespecially if this is part of a region-wide
response."
9. EELGC/EERA is aware of a research study[23]
undertaken by the former Department of the Environment, in the
early 1990's, which suggested that house prices in the South-east
could be reduced by new housing supply only if the scale of development
were very large and fairly generally distributed across the South-east.
10. The London-Stansted-Cambridge study consultants noted
that:
"The scale and speed of development required by the higher
growth scenarios poses a formidable challenge to the development
industry[24]; and
indeed to other supply sectors in the economy (training, transport
etc). Regeneration and development will not be easy in a number
of the areas (Lee Valley, major regeneration of Harlow, provision
of local transport systems etc.) and the report suggests the need
to look at special delivery mechanisms and institutions to ensure
that the required time-scale is met."
11. EELGC/EERA is therefore concerned that major development
in the potential growth areas could only reduce house prices at
the expense of considerable conflict with economic and environmental
pressures. It may also be beyond the ability of the development
industry to deliver. If this proved to be the case, high rates
of growth would need direct Government intervention in planning
and building major development and/or new towns.
12. EELGC/EERA is also concerned that growth should not
be housing-led. Whatever level of development is proposed must
be based on a balanced package of employment and housing development.
To proceed otherwise would create unsustainable development and
transport patterns, and would frustrate, rather than achieve,
the Government's aim of creating sustainable communities.
Question: The geographical distribution of new housing, including
plans to concentrate development in the South East in four growth
areas, Milton Keynes, the Cambridge/Stansted Corridor, Ashford
and the Thames Gateway
13. Achieving the right location for housing development
within the study area is vital. The Deputy Prime Minister's statement
focuses on housing provision but this must be seen in the context
of an overall strategy for the study area. New housing must be
located close to jobs and areas of job potential. It must also
be located where major investments in public transport and road
infrastructure are planned. Otherwise new housing will not meet
the needs identified by Ministers and will create unsustainable
commuting travel, congestion and environmental harm. RPG14 will
seek to deliver such an integrated long-term strategy.
14. Housing alone is not the answer for those areas,
such as Harlow, in need of regeneration. Investment is needed
in physical and social infrastructure and jobs to support existing
communities, which may then enable further, sustainable residential
growth.
15. Growth at Stansted will have a major impact on the
economy, housing and transportation of the region. The SERAS White
Paper expected in mid-2003 will contain the Government's proposals.
These may have a major bearing upon the pressure for and ability
of the corridor to accommodate major housing and employment growth.
It may also have a major impact on infrastructure needs.
Question: Whether the proposals will promote high quality sustainable
communities whilst avoiding poorly designed urban sprawl
16. This issue is addressed in response to the question
on "the overall scale of housebuilding required".
Question: Proposals for new Millennium Villages
17. EELGC/EERA has no experience of such developments.
However, the RPG14 Options Consultation invites public comments
on the possibility of concentrating a significant proportion of
future growth in a major new town (or several smaller new towns
of equivalent overall size). It makes clear that if such an option
were pursued it would have to deliver a highly sustainable development,
with maximum opportunity for economic growth and/or regeneration,
and that good public and private transport links and high environmental
quality would be essential.
18. Most Millennium Villages built or proposed so far
are considerably smaller than those implied by the Deputy Prime
Minister's statement and the London-Stansted-Cambridge study.
If a new town option were selected for the East of England, the
level of growth needed could be nearer to the scale of a large
new town.
Question: The balance of new development between housing for
sale and social housing
19. The term "social housing" does not encapsulate
the full range of affordable housing issues. We use the definition
given in Circular 6/98:
"the terms affordable housing or affordable homes . .
. encompass both low-cost market and subsidised housing (irrespective
of tenure, ownershipwhether exclusive or sharedor
financial arrangements) that will be available to people who cannot
afford to rent or buy houses generally available on the open market".
20. RPG9 set a target of 18-19,000 affordable homes per
annum for the areas outside London. This equated to a target of
46-49% of total supply. EELGC's first Annual Monitoring Report
(2001) showed that affordable housing makes up about 13% of total
supplythough this misses out much low cost market housing,
which is difficult to identify. The need for affordable housing
is the subject of continuing research, but is believed to be at
least 20% of total supply, and possibly higher in some areas.
21. The delivery of affordable housing rests on three
key sources:
(i) direct provision by Local Authorities and Registered
Social Landlords (RSLs) relying upon Housing Corporation finance;
(ii) provision by developers within market housing developments
(though this usually also relies on the availability of an RSL
to manage the housing in the longer term). This provision is usually
secured by S.106 agreements[25];
and
(iii) contributions by developers in the form of cash
or land, also usually secured by S.106 agreements.
22. The reliance on delivery of affordable housing via
S.106 agreements is a great weakness. This is a major subject
in its own right, and EELGC (and SEERA[26])
submitted reports on this issue to Lord Rooker earlier this year.
In brief, provision via S.106 agreements:
(i) cannot meet all needs for affordable or key worker
housing;
(ii) is time-consuming and fraught with risk of failure;
(iii) imposes a significant burden upon private developers;
(iv) is frequently frustrated by the lack of Housing Corporation
or other funding to enable an RSL to manage the housing;
(v) cannot be applied to developments below certain threshold
sizes, such that many developments make no contribution at all[27];
(vi) are particularly difficult to secure for developments
on brownfield or recycled land, as developers' ability to provide
is often more limited, and many such sites fall below the thresholds
(sub-para v. above).
Question: The extent to which decisions relating to housing,
including numbers, tenure and density, should be taken by central
and local government
23. EELGC/EERA considers it essential that decisions
on these issues should initially be taken by local government,
via the plan-led system, for the following reasons:
(i) As indicated above, DPM's statement focuses on housing
provision but this must be seen in the context of an overall strategy
for the study area. Housing and jobs need to go hand-in-hand otherwise
increased (and unsustainable) commuting will result;
(ii) Development of a strategy for the study area will
be built into the RPG 14 process. As indicated earlier, EELGC
is currently consulting on options. We aim to submit Draft RPG14
to ODPM by June 2003 and are currently on target. Final RPG14
should be completed by the second half of 2004 (in line with ODPM
target).
(iii) Stakeholders are expecting full consultation before
proposals for the corridor are finalised. The London-Stansted-Cambridge
study included a number of consultation events, and consultees
expect further consultation as part of the RPG process;
(iv) It is vital, for the credibility of this and future
studies, that its outcome is not seen as a "done deal"
before the consultation processes have been completed. It is also
important that the key players are signed up if the strategy is
to work;
24. The overall democratic process is, therefore, vital.
The RPG process provides for policy to be prepared by representatives
of accountable public bodies, while EELGC/EERA is also following
an inclusive process with stakeholders. The process further affords
opportunities for formal public objection and the opportunity
to submit evidence, either in writing or in person, to a Public
Examination, and to object to proposed changes after that stage.
25. While mindful that the DPM has published proposals
for reform of the planning system to speed up development, the
subsequent stages in the planning process will also afford opportunities
for public scrutiny of the more detailed stages of development.
It is vital that proposals be subject to such scrutiny, to ensure
public credibility, support, and hopefully acceptance and buy-in.
Any suggestion that the proper democratic process will be undermined
needs to be avoided.
22
Figures extracted from London-Stansted-Cambridge Study. Back
23
We believe the study was titled !The Relationship between house
prices and land supply" but do not have a copy of it available
to us. Back
24
Our emphasis. Back
25
S.106 Town & Country Planning Act, 1990. Back
26
South East England Regional Assembly. Back
27
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